PRIVACY PROTECTION POLICY RE: PERSONAL HEALTH INFORMATION MANAGEMENT

​Privacy Policy

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Solstice Psychotherapy, referred to as CLINIC throughout this disclaimer, (“we” or “our” or “us”) is committed to responsibly and accurately collecting, using and disclosing your personal health information to provide you with the highest quality of service. This Privacy Policy sets out why your personal health information is collected, to whom your personal health information will be disclosed, the data security protections CLINIC has in place, and your personal health information rights.

 

Categories of Personal Health Information Collected

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In the course of providing treatment, CLINIC will collect information about you. The types of information collected will vary in accordance with the circumstances, but may include information such as:

• Demographic information: name, date of birth, contact information, gender, sexual orientation, ethnicity, religious affiliations, substitute decision maker/next of kin.

• Employment and education information: level of education, place of employment, type of occupation.

• Health information: record of your visits, diagnoses, symptoms, health and functional history, assessment/testing results, medication, family medical history, provincial health insurance number.

• Payment information: banking information, credit card information.

 

Methods of Collection

 

CLINIC will collect personal health information from you directly, through questionnaires and information provided during treatment sessions, or in communications with us. We may also collect information indirectly through the review of records or through publicly available sources. CLINIC may also collect information about you from third parties (e.g. person or organization that referred you for treatment, e.g. family physician, employee assistance program, etc.).

 

How the CLINIC Uses and Discloses Personal Health Information

 

The CLINIC may use and disclose your personal health information for the purpose of service delivery, providing treatment and additional services recommendations, communicating with you and operating our business (“Services”). The following is a list of purposes for which we will use and disclose your information:

• Provide treatment and care to you

• Communicate with you about appointments

• Carry out our administrative and internal business operations

• Collect payment for the Services provided to you

• Carry out quality assurance for the Services

• Obtain your consent (or that of your substitute decision maker) when required

• Respond to or initiate proceedings

• Comply with regulatory and legal requirements

• Fulfill other purposes permitted or required by law, such as the need to eliminate or reduce a significant risk of bodily harm, to comply with a court order, warrant or subpoena, etc.

• OPTIONAL:

  • Carry out research (special rules apply)

  • Compile statistics

 

We will not disclose more information than is reasonably necessary to meet one of these purposes. All information collected, used and disclosed will be done in accordance with applicable law.

 

Consent for the Collection, Use and Disclosure of Your Information

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You generally have the right to control how your information is collected, used and disclosed, subject to limited exceptions provided in law.

 

For most health care and treatment purposes, your consent to collect and use your personal health information is implied, unless you instruct us otherwise. We may also share your information with other health care professionals that are providing you care, unless you instruct us not to do so.

 

Your consent is required to disclose your information to third parties that are not providing you healthcare, such as your insurance company, a benefits provider, etc.. In most circumstances, we will also not share your information with your family members or your friends (unless they are your substitute decision maker), without your consent. To disclose your information to third parties that are not providing you healthcare, your explicit consent is required. When we ask for your consent, you are able to say no. You are also able to withdraw your consent after it has been given, subject to certain regulatory and contractual obligations. Your withdrawal of consent may impair our ability to provide you with the Services. The withdrawal of your consent cannot be retroactive.

 

There are circumstances permitted or required by law in which your consent to collect, use or disclose your information is not necessary. For example, your consent is not required for billing or quality assurance purposes; to disclose personal health information in required circumstances, including to eliminate or reduce a significant risk of serious bodily harm; or to fulfill mandatory reporting requirements, such as risk of harm to a child.

 

Correction of and Access to Personal Information

 

We will take reasonable steps to ensure that the personal information collected is accurate and up to date. CLINIC relies on you to disclose all material information accurately to us. If you believe there is an error in your information in our records, you have the right to request that it be corrected. You are required to show that your information is inaccurate or incorrect before it will be corrected. It is also necessary for you to provide us with the correct information. We will not accommodate a request to correct your information if, in our opinion, it would violate a law or legal requirement. We are not required to correct information relating to clinical observations or opinions made in good faith. We will not correct a record that was not originally created by a member of the CLINIC team and we do not have sufficient knowledge, expertise or authority to correct the record. You have a right to append a short statement of disagreement to your record if we refuse to make a requested correction.

Subject to limited exceptions, you have the right to access your information. If you request a copy of your record, one will be provided to you at a reasonable cost, which will be disclosed in advance to you. If you wish to view the original record, one of our staff members must be present, and a reasonable fee may be charged for this access. We have 30 days to provide a response to a correction or access request, subject to a permitted extension. If you are not satisfied with our response to your access or correction request, you are entitled to contact the Information Privacy Commissioner of Ontario (contact information below).

 

Protection of Your Information

 

CLINIC acknowledges and understands the importance of protecting your information. We are committed to protecting your information against unauthorized access, use, loss, modification and disclosure. CLINIC employs industry practices to protect your information. These data protection safeguards include: [only include the safeguards you are currently using in your practice]

• Physical measures, such as restricted access areas in the clinic, locked filing cabinets.

• Organizational measures, such as restricted access to client records, privacy policies and procedures, confidentiality agreements, privacy training for staff, risk assessments, vulnerability audits.

• Technological measures, such as the use of passwords, multi-factor logins, encryption, and intrusion prevention and detection software.

• Video conferencing security measures, such as the verification of your identity. [not needed if do not carry out virtual healthcare]

CLINIC relies on employees, contractors and third party service providers to operate our practice and deliver the Services. Your information will only be shared with these parties to the extent necessary. For example, CLINIC utilizes a third party service provider, [name of EMR provider] to maintain electronic client records. Any third party service provider is required, contractually or through other means, to have appropriate security measures in place to protect the privacy and information of CLINIC’S clients.

 

In administering our practice, we make use of a secure, web-based practice management system to store and manage our client records. This includes information such as client appointments, billing documents, session notes, contact details, and other client-related information and documents. The system we use is encrypted, has servers exclusively located in Canada and access to the system is granted only on an as-needed basis and governed by our strict confidentiality policy.

 

Despite the security safeguards that CLINIC has in place to protect your information, given the nature of the internet and electronic communications, it is possible that your information may not be secure and is vulnerable to data breach, among other risks. We encourage you to take appropriate steps to protect your information, including not sharing more information than necessary with us, and not sharing your account information with anyone else.

 

Retention and Destruction of Records

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CLINIC retains client information only for a long as is necessary, including for legal and accounting purposes, in accordance with applicable legislation and the College of Social Workers and Social Services Workers regulations and standards for record keeping. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you.

 

Once your information is no longer required to be retained, CLINIC will destroy your record, whether electronic or paper format, in a secure manner that prevents anyone from accessing, discovering or otherwise obtaining your information.

 

Questions or Concerns

 

Should you have any questions or concerns about this Privacy Policy or CLINIC’s information management practices, or if you would like to make an access or correction request, please contact the director of Solstice Psychotherapy, who can be reached at: connect@solsticepsychotherapy.com

 

You also have the right to complain to the Information Privacy Commissioner of Ontario.

Information and Privacy Commissioner of Ontario

2 Bloor Street East, Suite 1400

Toronto, ON  M4W 1A8

Tel: 1-800-387-0073

Fax: 1-416-325-9195

or visit the IPC website via www.ipc.on.ca

 

​PRIVACY POLICY RE: WEBSITE USE

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This policy tells you how we collect and use information.

Thank you for visiting www.solsticepsychotherapy.com, the website of Solstice Psychotherapy, originally founded by Janice Gill in Ontario, Canada. We respect and protect the privacy of our users.

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If you contact us, we will collect the email address you nominate and any other identifying information you provide, such as a name or phone number. We may use this information for Solstice Psychotherapy marketing purposes. We will never sell this private information to third parties.

 

Please read this Privacy Policy carefully. We will alert You to any changes to this Policy by changing the “last updated” date at the top of this Policy. Any changes become effective immediately upon publication on Our website, and You waive specific notice of any changes to the Policy by continuing to use and access Our site(s). By accessing and using this website, you agree to this privacy policy. If you do not agree with this privacy policy, please do not use or access this website.

 

What is Personal Information?

“Personal information” is personally identifiable information such as your name, residential address and email address and includes information about your products, services, subscriptions and usage, credit card information and billing records. It does not include the name, title, business address or telephone number of an employee of an organization.

 

What kind of personal information does Solstice Psychotherapy collect?

We collect various types of personal information including: Your name, shipping address, email address, telephone number, credit card information, or demographic information like Your age, gender, or hometown. You consent to giving Us this information by providing it to Us voluntarily on Our website or any mobile application. You provide some of this information when You register with or make purchases from Our website. You may also provide this information by participating in various activities associated with Our site, including responding to blogs, contacting Us with questions, or participating in group training. Your decision to disclose this data is entirely voluntary. You are under no obligation to provide this information, but Your refusal may prevent You from accessing certain benefits from Our website or from making purchases. This information will be used for the primary purpose for which it was collected, which may include: responding to your message, communicating with you about the requested service or product, and processing payments for any and all purchases made by you through the website and links.

 

Solstice Psychotherapy also collects certain technical information from your computer each time you request a page during a visit to our website www.solsticepsychotherapy.com. This information is collected from your computer’s Web browser to enhance your experience on our web site and may include your IP address, desktop or mobile operating system, Web browser software, screen resolution, and referrer Website.

 

How Does Solstice Psychotherapy collect personal information?

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We collect personal information that is voluntarily provided to us by our customers, members, sponsors, web site users and the public in general when they contact us via telephone, e-mail, web browser, or in person. As mentioned above, we may also collect personal information from our business partners and other third parties who have agreed to obtain the consent of the person the information pertains to before disclosing the information to us. Solstice Psychotherapy may also collect personal information through the following means:

i) Cookies .A cookie is a piece of data stored on a web site user’s computer hard drive containing information about the user. Cookies automatically delete this information from our computer storage system after 30 days, but permanent cookie files remain on the user’s computer’s hard drive until they manually delete the file. Solstice Psychotherapy can use cookies to deliver content specific to your interests and to save your password so you don’t have to re-enter it each time you visit our website. Cookies, by themselves, cannot be used to disclose your individual identity. A cookie will identify your browser, but not you, to our computer servers when you visit our website. Most browsers are initially set up to accept cookies, but you can set your browsers to refuse cookies. However, if you do not accept cookies, you may be limited in some areas of our website.

ii) Web beacons. To assess the effectiveness of promotional and marketing emails we send, we may attach a web beacon to the email that provides us with confirmation when the recipient opens the email. This only occurs if the recipient’s computer supports such technology.

iii) Google Analytics, Shopify Analytics + Facebook Pixel. We may partner with third-party analytic companies, including, but not limited to, Google Analytics, Shopify Analytics, Facebook Pixels. The analytic companies may also use cookies (described above) or other tracking technologies to analyze visitors’ use of Our website or mobile app to determine the popularity of the content, and better understand online activity. We do not transfer personal information to these third-party vendors. However, in order to access Our website, You must consent to the collection and use of Your information by these third-party analytic companies. You should review their Privacy Policy and contact them directly if You have questions. If You do not want any information to be collected and used by tracking technologies, visit the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.

 

Why does Solstice Psychotherapy collect personal information?

Your information allows us to offer you certain products and services, including the use of our website, to fulfill our obligations to you, to customize your interaction with our company and our website, and to allow us to suggest other products and services we think might interest you. We generally store Your data and transmit it to a third party for processing. However, to the extent We process Your data, We do so to serve Our legitimate business interests (such as providing You with the opportunity to purchase Our goods or services and interact with Our website or mobile app).

 

Collecting Data from Children
This website or mobile app is not designed for use by children under age 16, and We do not knowingly solicit personal data from anyone under age 16. If You are under age 16, do not access or use Our website or related products or services. If You become aware that We have collected data of anyone under the age of 16, please contact Us so that We may delete that data.

 

Sensitive Data
We request that You do not submit any sensitive data to Us, via public postings, email correspondence with Us, or any other method, including social security number, health data, genetic data, or information related to Your ethnic origin, religious beliefs, or criminal history. If You do send Us this information, then by doing so You are consenting to Our use, storage, and processing of this information in accordance with this privacy policy.

 

Verifying and Amending Your Personal Information

Solstice Psychotherapy tries to ensure that all personal information about you that is in our possession is accurate, complete and up-to-date. To enable us to do so, please inform the person to whom you provided your personal information of any change to that information.

You can inquire about, access and review your personal information held by Solstice Psychotherapy and make corrections to it. Please send us an email to connect@solsticepsychotherapy.com for assistance with these matters. In some cases, Solstice Psychotherapy will be prevented from disclosing the requested information to you. If any request you make for access to personal information is denied, we will provide you with an explanation.

 

Website Analytics / Cookies

To improve your experience on our site, we may use 'cookies'. Cookies are an industry standard and most major websites use them. A cookie is a small text file that our site may place on your computer as a tool to remember your preferences. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.

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Our website may contain links to other websites. Please be aware that we are not responsible for the privacy practices of such other sites. When you go to other websites from here, we advise you to be aware and read their privacy policy.

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Our website uses Google Analytics, a service which transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and web page usage.